May 20, 2020
Pandemic Serves as Stress-Test for E&C Programs
There is nothing like a worldwide pandemic to see how well your ethics and compliance program is operating. If nothing else, COVID-19 is answering the question every ethics and compliance executive is asking: Just how strong is my E&C program?
Put another way, the crisis is proving to serve as a stress-test for E&C programs, said Edward L. Queen II, director of the D. Abbott Turner Program in Ethics and Servant Leadership, at Emory University’s Center of Ethics.
“It’s easy to do the right thing when it’s easy to do the right thing. Times of crisis and uncertainty...are going to tell the extent to which the compliance program, the ethics program, has embedded itself within the culture,” said Queen on Monday during a panel discussion led by LRN’s Susan Divers as part of the Compliance Week virtual conference.
It’s when people feel forced to make decisions in an unknown environment that they either take hold of, or reject, the training, ethics, and culture they’ve experienced in the organization. “That’s where you really see the extent that your expressed values really have become the real values of the organization, or not,” said Queen.
Divers--author of LRN’s 2020 E&C Program Effectiveness Report, which was released officially this week--said COVID-19 has led to inspiring examples of organizations going way above beyond what is required of by them by laws and regulations.
“They are doing the right thing, even at a cost,” said Divers, citing as examples employees at three companies who locked themselves in their plants and self-isolated "to ensure the electrical grid is operating, or to produce needed medical equipment. That’s not something any law could come and tell them to do. They chose to do it.”
Companies that PEI deemed as having high-impact programs had leaders at all levels of the organization model the behaviors and values espoused in the code of conduct. They created cultures that embed ethics into the “drinking water” of the organization, and were not just words in rarely read documents.
High-impact programs integrate ethics and compliance into all aspects of decision-making, planning, and operations. That means “E&C has a real seat at the table, and is not just some scattered elements that we have to comply with; it’s a real program that has a heart that beats,” said Divers.
Paul Gennaro, senior vice president of brand and corporate communications, and chief brand and communications officer for Voya Financial, told the webcast audience the company stepped up communications when more than 95% of its employees were told to work at home.
Voya continues to get participation rates exceeding 80% and 90% for its town hall meetings, and is seeing strong appetite for messages from the chief executive, which led to weekly podcasts. For customers, fees were waived if money needed to be withdrawn from accounts that normally would charge a penalty to do so, and financial information once restricted to customers was made free to the public.
The company sponsored an online concert for first responders and essential workers, featuring a singer who is deaf as a way to showcase its efforts to improve diversity and inclusivity. “We’re trying to go back to our values and our culture, to focus on what can we do right as we go forward,” said Gennaro.
Michael Blackshear, global chief compliance officer at insurance business Ryan Specialty Group, said his team’s efforts have focused on how to be creative, and how to interact to ensure the more than 2,500 employees who now are working at home are adhering to not only standards set by regulators, but also to the behaviors demanded by the company as expressed in its code and its values.
“It’s managing past that fear of the unknown, to go to the point where you can pivot for that level of creativity for that new normal,” said Blackshear. “Who we are today is not going to be who we are tomorrow, after we embrace and adapt to this new pandemic, but the first step is to manage past that fear."
When responding to any situation like this, the first thing an organization has to do, beyond building a consistent line of ethical behavior, is to manifest imagination when addressing issues of work, safety, and everything else that arises as a result of this pandemic, said Queen.
“That is going to be I think what we’re going to see between organizations that are successful and less successful,” said Queen. “People and organizations may manage to survive, but those that are going to thrive are those that have responded imaginatively to these multiple demands.”
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